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Case 1:08-cr-20612-PAS

Document 116

Entered on FLSD Docket 11/20/2008

Page 1 of 3

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No: 08-20612-CR-SEITZ/O’SULLIVAN

UNITED STATES OF AMERICA ) ) Plaintiff, ) vs. ) ) TRAIAN BUJDUVEANU ) ) Defendant. ) ____________________________ ) NOTICE OF APPEARANCE, PLEA OF NOT GUILTY DEMAND FOR DISCOVERY AND VIEW OF EVIDENCE MICHAEL B. COHEN, P.A., Attorney at Law, 6400 North Andrews Avenue, Suite 460, Fort Lauderdale, Florida 33309, hereby files this Notice of Appearance in the above captioned case. THE DEFENDANT, by and through undersigned counsel, tenders, this Plea of Not Guilty to the above styled Indictment on all counts. FURTHER, the Defendant hereby waives reading of the Indictment and formal arraignment, and will plead not guilty before this Honorable Court at the time of his arraignment. FURTHER, the Defendant moves this Honorable Court to grant the Defendant 45 days to file applicable motions, including motions attacking the Indictment. IT IS HEREBY requested that a complete copy of the Indictment filed in this case be forwarded to the undersigned by the Clerk of the Court UNDERSIGNED COUNSEL REQUESTS that the Clerk of this Court hereafter forward to the undersigned copies of all pleadings and other documents filed in the above captioned matter, and further,


Case 1:08-cr-20612-PAS

Document 116

Entered on FLSD Docket 11/20/2008

Page 2 of 3

IT IS HEREBY requested that the Clerk of this Court promptly notify the undersigned of the time, date, and place of the arraignment and all hearings, reports soundings and of the trial to ensure prompt appearance of the Defendant and the undersigned counsel before the Court. THE DEFENDANT respectfully demands a trial by jury. NOTE TO THE CLERK; Undersigned counsel hereby requests that he be immediately notified of the trial date in the instant case. THE DEFENDANT further demands that the United States Attorney’s Office of this District furnish and disclose the Defendant’s undersigned counsel all discovery and evidence, due pursuant to the courts standing Discovery Order.

Respectfully submitted, s/ *Michael B. Cohen, Esq.* _________________________ Michael B. Cohen, Esq. Florida Bar No: 210196

IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing was furnished via CMECF this November 20, 2008 to all applicable parties.

Respectfully submitted, s/ *Michael B. Cohen, Esq.* _________________________ Michael B. Cohen, Esq. Florida Bar No: 210196 6400 North Andrews Ave Ste 460 Fort Lauderdale, Florida 33309 Ph (954) 928-0059 Fax (954) 928-0929


Case 1:08-cr-20612-PAS

Document 116

Entered on FLSD Docket 11/20/2008

Page 3 of 3


doc 116